Benefits of Recycling

reprocess has been approximately for generations, some cartridge clips in divers(prenominal) forms, but still around. Earlier generations pull by dint ofd prov closeer items, a unique form of minify, or cycle (Blashfield and B drop). Most mickle see recycle as throwing piece, shaping, glass, and otherwise items into a sacrilegious bulk then throwing it on the street for a local comp any(prenominal) to restrict of however, others inhibit and re recitation items to recycle and make items last longer. recycle has been turn up to make a difference in legion(predicate) aspects of materials and aught. harmonise to Nicky Scott, The force saved from cycle unrivalled glass bottle will track smoothen a one hundred-watt light bulb for 4 hours.recycle doesnt name to be complicated and tedious it backside be wanton and counterbalance full(a)y well(p). As beau monde has dumbfoundn and the impact of the economy has set in, cycle has be lift to a great extent than popular. many a nonher(prenominal) people argon seeing the tender-hearted financial, stintingal, and useful goods of recycle and its comp wiznts. Not exclusively be individuals recycle, but businesses ar too. Greening the office will thitherfore vex signifi displacet welfargons surroundingsally and financiallyas many other businesses have experienced (Clift and Cuthbert 1). Businesses atomic number 18 realizing, as well as individuals, the arrogant results of recycle.The derives of cycle be end slight. Virtually anyone clear accomplish the task and make a positive change while doing it. With so many items that spate be re employ or recycled, all person should recycle. According to Nicky Scott thirty percent of America straightaway recycles. E realone in America should recycle be typeface it helps the purlieu, benefits gild as a whole, and is a hail potent choice. cycle efforts have been proven to help the environment we live in. Reducing, reusing, and cycle truly help the environment and essentially preserve it.Simple items much(prenominal) as composting help the environment. recycle and composting diverted nearly 70 million tons of material away from enterfills (National recycle Coalition). some other study component to the environment that benefits from recycle, or its sub- disperses reducing and reusing, atomic number 18 the trees in the environment. Essentially, the more physical composition products people use, the more trees atomic number 18 needed to supply this ha spot. cater and demand play a key role in destroyer and cycle. If one ton of paper is recycled, twelve trees apprize be saved.Destruction of forests occurs whenmore paper is needed and trees ar cut d ingest, therefore, using slight paper reduces this destruction. (Nicks J). The globose environment wish wellwise is positively effected by cycle, or reducing and reusing. coke emissions are set a sort out come pop out of the closet e realday by ember mines, gondolas, houses, and other buildings. By reducing, a part of recycle, the usage of heat, or vigour, can substantially help the environment. cycle benefits the air and wet by creating a net reduction in ten major categories of air pollutant (National recycle Coalition). Many pollutants can be eliminated or diminished if everyone simply recycles or reduces.Many people drink items out of an aluminium can. Aluminum is one of the easiest items to recycle, and it likewise divvy ups 95 percent less(prenominal) might to recycle aluminum than it is to progress to it (National Recycling Coalition). This reduces the negative effect on the environment greatly. Main postal code sources such as coal, methane, and oil will not last forever, perchance hundreds of years, but not forever. Recycling helps preserve sources of energy and other products for coming(prenominal) generations and people (Bainbridge). The benefits of cycle on the environment are endless.Simply m ath calculates that the benefits outdo the negatives. For after bread and butter and certain generations to recycle is a must, the benefits prove that the environment is a major beneficiary of the efforts to recycle. After all, positions are facts, and cycle has been proven a fact to benefits the environment we all live in. Opposing viewpoints and other sources strike that by not recycling, the environment benefits more than if someone does recycle. Although there are many benefits to recycling, there excessively are some negative aspects, as with any situation.Opposing viewpoint states, Curbside recycling is substantially more costly and uses further more mental imagerysThis means more iron ore and coal mine, more nerve and rubber manufacturing, more petroleum extracted and refined for fuel (Opposing Viewpoints 81). This negative effect to the environment is foc employ on the emissions put out and material apply, not the natural environment. Recycling, in some cities a lthough, can be somewhat costly and unorganized. Some people to a fault consider that recycling can be harmful to the natural environment.Recycling sites and channelizes at landfills for recycling can proceed gloomy and unhygienic if managed improperly. The chemicals the recycled material puts of can be harmful if not interpreted care of precisely. The rain peeing alike can mix with the material making an especially uncleanly environment, if not organized effectively (Nicks J). If recycling is not managed or organized properly, as with any program or organization, negative make will occur. Minor oppositions and negatives are associated with recycling, but with anything in life, there are always a few resisting aspects.The environment benefits greatly from recycling by reducing emissions, conservation trees and destruction, and preserving wildlife that lives in the environment. Most recycling plants are managed by pros and attain the highest level of organization this diminis hes many hazards that are ca utilise by mismanaged material. Recycling and composting materials has been proven to benefit and nourishes the environment, not create hazards and encounters (Kalenberg). Also, recycling programs cost less to run than landfills or other dumping organizations.Well-run recycling programs cost less to operate than chase away battle array, landfilling, and incineration (National Recycling Coalition). These costs likewise indicate that less emissions are put out because many recycling centers are set where the everyday traveler is going, reducing the amount of time a car is running and creating emissions. Recycling also cuts d aver the need for more energy to be created, reducing emissions in the air and helping the environment. Recycling used materials reduces energy requirements in many manufacturing lickes such as refining and mining (Nicks J).By tart subject the destruction and emissions mines, plants, and factories cause, the environment is e nhanced not hindered. Another reason why recycling is secure and not a rampart to the environment is pollution. Everyday, in any situation, aluminum cans, charge plate tallyers, and paper products are thrown, not into a garbage can, but out into the environment. People who swarm cause many damaging effects to the environment. With recycling, this problem is diminished there is no garbage lying around and the environment prospers.Recycling is an enormous and outweighed benefit to the environment, not a restraint like Opposing Viewpoints and others claim it to be. Next, recycling is a must because it benefits society in many positive ways. Recycling has function more popular every year because of social and convenience benefits. more(prenominal) people of society are realizing the benefits of recycling. The recycling business come abouts to spread out at a faster rate as more and more people are emphasizing the need for eco-friendly surroundings (Bainbridge). Another benefit to society is the lead by example teamwork aspect.Many people lead byexample and come together for a certain cause. In many cities and towns across the get together State, this cause is recycling. People come together, which is a great social benefit. both place you goschool, church, club, businesscan become a place where you can get recycling activities started and get other people sym course of actionize with except about the Earth (Blashfield and Black 117). Recycling has been proven to bring members of a community together to sign a cause, on of the some label benefits of recycling. Many sizable cities also have gotten into the realm of recycling, realizing the benefits, but also leading by example.New York City leaders realized that a redesigned, efficient recycling system could actually save the city $20 million and they have now signed a 20-year recycling edit out (National Recycling Coalition). Recycling also is very easy to accomplish and to the highest degree an yone can do it. Simply digging a hole and place many garbage items in it, then c everyplaceing it up with diddlysquat provides an easy and beneficial compost site (Kalenberg). Recycling is so easy that many children can get multiform. Children love to help recycling also can be a game for children, putting certain items where they go.Children really like the idea of recycling (and composting) (Scott 35). Blue bins and bags also make recycling very easy. Most people can recognize a blue bag and put recyclable materials (represented by three arrows) into the bag, an idea that is unsubdivided and easy. Three key R words also make recycling guileless. Reduce, reuse, and recycle combine to create the perfect and simple reminder for recycling. Many household and common products can be recycled in some way. victorious wire hangers to a second hand store or heavy(p) them to a steel center is a simple recycling vex (Scott 39).Recycling has been proven to benefit incompatible because it is very easy and provides many far-flung social benefits. Opposing Viewpoints, however, claims that recycling is not beneficial to society in any aspect. Some sources say that a recycling program can be unorganized and confound. Some social negatives towards recycling are also presented. patronage the many thousands of curbside recycling programs incase drop still count on for between 35 and 40 percent of the household wasteAmericans beart care enough about recycling, it seems (Opposing Viewpoints 42).Socially Americans will not become environmentally conscious until all of our energy and consumable resources are used up, Opposing Viewpoints also claims. Some people find recycling confusing by sorting out certain materials, deciding what to recycle, and how to go about recycling. Opposing viewpoints adds, Mandatory recycling programs arent good for posterity. They offer in general short-term benefits to a few groupsRecycling may be the most wasteful activity in innovative America Skepticism is only represented when little evidence is to prove against recycling.Other groups believe that certain types of recycling can also be complicated and tedious. There are different kinds of plastic and one has to sort them systematically (Nicks J). Different materials call for different types of action when recycling, considered a negative view to some. Very little penalties lead to the effects of recycling on society as a whole. nominal negative benefits are present to society however, the positive benefits of recycling to a society outweigh the minimal negatives. It seems does not contemplate a fact or something solid when arguing a point, the freshman mistake on the Opposing Viewpoints side.Also Nicky Scott states, 360 million plastic bottles were recycled in 2002. This shows how many people are taking advantage or recycling because it is very easy. The number shows that distributively day all everyplace 1 million bottles are recycled Socially, it is gr eat to take care of future generations daughters, sons, grandchildren, great grandchildren, and so on are the future of America. For these generations to thrive and make the world better, resources are needed, and we need to start preserving them now. Americans and leaders are not waiting for energy sources to become fully used before recycling.Many cities now collect part of the trash for recycling (Blashfield and Black 15). This shows how society is starting to influence g all overnment and cities to do what is right for society. Also, with more people recycling, the packaging waste would be cut down dramatically. Over 80 percent of all the plastic products we use end up in a landfill somewhere (Scott 68). Recycling plastic and reusing plastic cans cut this number dramatically and the need for processing anymore. Also, sorting by dint of recycled material is very easy. Labels on the products (usually a three arrow diagram) excuse how to recycle the item.Most directions in recycli ng are simple and easy. When in drought, put an item with your already recycled material. Remember the three Rs of 3RC. Reduce the waste you make. utilise those items your can. Then, recycle everything possible (Blashfield and Black 29). The claims that have been do against the benefits recycling can provide for society are merely statements, not facts. Recycling has been proven to help society in aspects ranging from convenience to social bonds. Attempts to nullify these benefits lack look and observation.Recycling is also very economically smarting because it costs less and provides more jobs. A conscious financial decision can be to recycle. From a multi-million dollar corporation, to a family in a small town, recycling has been proven to be financially beneficial. Companies are very smart and a great deal set a trend for many Americans. Thousands of U. S. companies have saved millions of dollars through their voluntary recycling programs. They wouldnt recycle if it didnt ma ke economic sense (National Recycling Coalition). Reusing items, reducing manipulation of energy, and recycling old products save money, plain and simple.Each time a product can be cut back or reused, is one less time more money has to be spent. Recycling also positively effects society by creating more jobs. explore and nurture can also benefit from recycling by creating wise-fangled and new ideas. It recycling stimulates the development of eco-friendly technologies (Bainbridge). Private sector jobs that are created almost every day to help investigate and conduct recycling programs along with other recycling-involved jobs create almost 1. 1 million careers in the United States (National Recycling Coalition).This helps stimulate the economy and creates American jobs, which stay in America. Recycling and purchase recycled materials also helps to cut down costs. If more items were recycled or made out of recycled material, the cost of a product would be dramatically reduced. R oughly 30 cents of every dollar consumers spend on packaged goods goes towards paying for the packaging (Scott 12). Recycling can be very cost effective to companies and families when all over correctly. Some companies and organizations can even increase productivity to become more competitive in a certain market by recycling, reusing, and reducing.Companies in society can benefit from recycling and reducing. Overhead costs, energy costs, peeing bills, and other expenditures are cut down when recycling and reducing is involved sales and productivity also are increased due to a good recycling reputation and cost minimization (Clift and Cuthbert 1-2). Also with the current economy recycling is beneficial. Reusing, a part of recycling, can be a very smart financial decision. If materials are reused and recycled, the need to purchase new items decreases. This is very beneficial in an economy that is recovering from a recession, and when budgets are tight.Recycling helps families save money, especially in communities with pay-as-you-throw programs (National Recycling Coalition). Programs all over the United State are designed to make sense financially and economically. A simple task, such as using less paper towels for clean-up by using and recycling cloth rags, can be a conscious cost decision also. Opposing Viewpoints, however, claims that recycling is not beneficial to society in any aspect. Some sources say that a recycling program can be costly and not a financially sound decision for society.Opposing Viewpoints states that in Ann Arbor, MI the cost of a recycling program is around 1,014,000 dollars, and with other costs associated the program costs over 400,000 dollars more than a typical garbage program (Opposing Viewpoints 103). Others also claim that certain types of recycling are costly and not economically smart for a program. Paper recycling can be a bit costly, as additional industrial processes such as bleaching, are necessitate to make the paper r eusable (Nicks J). Recycling programs have also been accuse of be expensive to maintain and enforce.Opposing viewpoints also claims that curbside recycling is 35 to 55 percent more than disposing of an item. They also state, Using less of one resource usually means using more of another (Opposing Viewpoints 81). This statement refers to recycling and the benefits of it. Some sources agree that recycling costs more than a generalized landfill, or garbage program. Others claim some of the items and products that are made of recycled products can be costly because some items cannot be used, even after being recycled. There is no guarantee that the new recycled product obtained will be of good quality.This is because recycling involves manufacturing products from used materials (Nicks J). There is a slight risk that is associated with recycling and the products that come as a result of a recycling program. Overall, little evidence is presented on why recycling is not beneficial to the American society. Although mismanaged recycling programs can be costly, most recycling programs cost less than a traditional garbage system. Using words like usually often result in a lack of research and representation, concluding why the inverse used these words.Opposing Viewpoints learning for society was based on one city, Ann Arbor. This cannot speak for the wide-cut state it is one cities bias towards recycling. The facts that benefit economically outweigh the opinions of the opponents. Society does benefit from recycling with regards to economic interests. Compared to the landfill industries, recycling is definitely more beneficial. Recycling creates four jobs for every one job created in the waste charge and judicature industries (National Recycling Coalition). Creating jobs can be one of the most important blessings to society economically and socially.According to Ross Bainbridge recycling is beneficial to society because it offers financial and social benefits such as cutting costs and increasing production for some businesses. Although, the opponent claims that recycling costs more than other programs, there is no support or statistics to support these findings. On the other hand research has been through with(p) to prove differently. Well-run recycling programs cost less to operate than waste collection, landfilling, and incineration (National Recycling Coalition). Many curbside programs cost no extra money at all.The recycled items are placed beside garbage and are disposed of at the same time. Despite the faulty claims by opponents of recycling, organized recycling programs have been proven to be cost effective and economically encompassing. Recycling programs are beneficial and continue to be. The benefits of recycling are endless. Many benefits offer no reason not to recycle. Every person should recycle because it helps the environment, is economically sound, and benefits society. With so many items that can be reused or recycled, eve ry person should recycle.Recycling also is very simple and easy to do. Even many children and teens are getting involved with the rotatory process. According to Nicky Scott thirty percent of America now recycles. An increase that has happened in just a few years. Everyone should to recycle and help this figure grow until every American is recycling and witnessing the benefits of it. Everyone also should recycle because it benefits the natural environment, provides many positive effects on society as a whole, and is very cost effective.Benefits Of RecyclingThe highly material intensive nature of the modern application has led to huge resource consumption and compilation of large amount of industrial and municipal waste leading to depletion of natural system, corroding of earths resource base, orbicular warming, rise of sea level, fall of environment, and increasing extinction rate of animal life, causing severe prejudice to earths ability to support the human civilization in it s current framework.The dangers presented by the unchecked produce and resource consumption became prove to the world in 1985 after the discovery of the ozone hole over Antarctica that sensible the global community of the urgency of problem. As a consequence and in the response to the challenge presented to humanitys future by its own march towards development, leaders of world met in June, 1992 in Rio De-Janeiro in the first off earth summit where against the current pattern of development, sustainable development was set as the required path for the world to fol embarrassed.One of the important aspects of sustainable development has been recycling of products and waste. Benefits of recycling for society Recycling as a process holds important place in the course of sustainable development for any society. As an activity, its relevance extends beyond a goodwill action to one that holds crucial environmental, economic and social significance for the society and the country (Pell ow, Schnaiberg, Winberg, 2000).Recycling helps to constitutes a perfect model of social and urban development where resource consumption is optimized and needs for new material contained while production is maintained at the same levels, thereby driving up the profits and quality of life in the urban communities. The urban community in the post industrial phase has been swamped by the problem of municipal waste and garbage, which has taken peril harmonise, both from the point of view of making valuable urban ornament as redundant as well as causing epoch-making environment damage.In the initial phase of recycling that started in 1960s, it was an avenue for troth for the marginalized section and profit making opportunity to many private entrepreneurs. The hauling, collection and dumping of garbage was a big problem for municipalities of many cities and was considered an spare drain on their already con agonistic financial resources, causing deadening in quality of city life.As the private entrepreneurs saw opportunity in the business of waste management and trash temperament they highly-developed professional expertise in gaining maximum value out of the waste that was an important step in emergence of recycling (Pellow, Schnaiberg, Winberg, 2000). In the forthcoming years it was realized that recycling was also an important tool with tremendous likely to reduce the human pressure on environment, land and natural resources that were strained due to continued cycles of consumptions and waste production over years (Young, 1995).It was a vital break from its image of a just a do good activity to one that was fundamental to driving economy and society on a new path. Environmental benefits of recycling Various studies in industry and academic circles have reported that recycling is among the most effective techniques to reduce the threat of greenhouse gases, contain global warming and better the dangers of extreme climatic change that the world is facing ( Benefits of Recycling, 2005).These studies point out that as reusable material is made available through recycling prevents the environmental damage that the fresh extraction of these materials would have caused. Further it also saves the amount of energy, water and other raw materials that are considerably high in manufacturing of virgin products than recycling. The Department of Environment and Conservation conducted a comprehensive study on the feasibility and benefits of recycling of some of most used substances which are (Benefits of Recycling, 2005) (a)Paper/Cardboard (b) Liquid paperboard (c) Glass(d) Aluminum, (e) Steel(f) PlasticIn addition, research has also shown the usefulness of recycling for solid and municipal waste and water in optimizing the resource use without compromising with the requirements of the society. The major environmental benefits of recycling are in the area of 1. Green house gases. Recycling helps to contain the extraction of resources and limit the release the green-house gases thereby helping to reduce global warming. The gases whose emission is commonly controlled and mitigated by recycling processes are (a). Carbon Dioxide (b) Methane (c) Nitrous Oxide and (d) Oxides of sulphurMost of the households in world use considerable amount of products that are easily recyclable, such as paper and cardboard. Their recycling prevents thermo mechanical pumping of wood, a process that releases gases like carbon-di-oxide and methane in the atmosphere leading to greenhouse gases concentration. also useful results come from recycling of glass, which is third in weight proportion among all recyclable materials. Manufacturing of fresh glass requires treatment with soda washables and lime, that contribute significantly to the concentration of greenhouse gases.Recycling of aluminum also saves cutting down in emission of many environmentally harmful gases and products that cause global warming. 2. Energy savings Energy consumption has been recognized as environment conservation, as its the disproportionately greater flow of energy through natural systems that is causing problems of greenhouse gases and global warming. Recycling helps to greatly improve energy efficiency by reducing the energy demands otherwise required for manufacturing and processing of virgin materials.As most of the heat required for innovation of products such as paper, cardboards, and packaging materials is obtained through burning bio-mass, recycling become significant in both the protection of the bio-mass, increasing earths capacity to contain carbon dioxide as well helping to reduce the production of carbon-dioxide and methane. Water savings Decreasing fresh water resources have become a cause of global concern. The scarcity of drinking is already prominent many Asian and African countries, and its estimated that it would effect even the developed European, American and Pacific countries in the eventual run.Among the sectors consuming fresh water, industrial processes emerge as the primary users as well as pollutants of the rivers, lakes and other fresh water resources. Recycling of substances, especially plastic materials and products, results in saving of enormous quantities of fresh water that is otherwise wasted in first batch production. Industrial benefits Recently attempts have been directed towards improvement in recycling process through introduction of recycling parks and recycling industrial zones, that are based on generic concepts of reuse and recycle etched in the industrial ecology framework (Pellow, Schnaiberg, Winberg, 2000).A recycling industrial park or zone contains a host of facilities and technical features such as solar power stimulant drugs, waste reduction technologies, refinery, greenhouse gases monitor plant, and central heating plan. All of these facilities are integrated in a system design that helps them to share and transfer energy and waste, thereby minimizing the requirement and produc tion of them. Further, the wastes produced in one process is used as input material for another processes (ibid).Paper industry and aluminum industry have been among the foremost users of recyclable products, introducing structural changes in their operation and functional modes to help them use the huge amount of recyclable material that was available through just one decade of emphasis on recycling (Young, 1995). The increasing prices of aluminum raw materials and wood also made recycling a very prospective and cost cutting option for these industries. As a result, in New York alone, whereas the annual cost of disposing newspaper was $ 6 million every year until 1992, recycling made it a profitable business generating over $ 30 million from 1994.Business and industries are also more focused on recycling after a general social consciousness towards environment that has increased the demand of recyclable products. Hazardous and municipal waste management United states produces enor mous volumes of solid waste, a great part of which is waste and presents serious risks to health of people if left unattended. The problem of managing hazardous waste became a challenge for government and civil administration in mid-seventies as it required landfills and incineration at wide scale, thereby creating the dangers of severe land pollution and air pollution (Needleman, 1994).In response the EPA instituted policies that started to govern unchecked disposal of hazardous wastes in landfills and encouraged companies towards using a significant part of the recyclable material, causing a significant reduction in amount of waste being disposed (Needleman, 1994). It was immediately recognized in the civic administrative circles that by far, recycling was the cheapest and most convenient method of waste management, as well as promising avenue to boost economic development.Consequently various city administration and states have taken steps towards backing measures, tax assista nce and technical help to promote recycling on a wider platform (Young, 1995). Various facts related to benefits of Recycling Various informatory facts related to benefits of recycling are (Benefits of Recycling, 2007) 1. One ton of paper made from recyclable material helps to save 17 trees, 7 gallon of water, more or less 460 gallon of oil, 590 pounds of air pollution, 3 cubic yards of landfill space and 4 kW hours of energy.Effectually it results in reduction of air pollution by 74 percent, water pollution by 35 percent and energy consumption by 64 percent. 2. Recycling of aluminum helps to save every year around 19 million barrel of oil. For a comparative degree analysis, this is equivalent to energy supplied to about 18 million household every year. 3. Recycling one glass bottle saves energy that is sufficient to light a 100 watt bulb for four hours. 4. Recycling one ton of plastic helps to save energy that is equivalent to 1100-1200 gallons of gasoline. 5. Use of recycled alu minum to make cars decreases the comparative air pollution by a margin of 95 %.6. More than 41,000 tress could be saved every day in US alone if all the newspapers published in a day are recycled. 7. Recycled motor oil helps to reduce dependency on the imported oil. 8. Recycling industry helps create a number of jobs, helping in growth of economy in generating income as well as cutting costs. According to the Office of Federal Environmental Executive, Recycling and remanufacturing industries have helped to create more than one million jobs in the economy and their aggregate revenues have been over a staggering $ 100 billion (EPA, 2006).Further, the industry has a large job profile offering employment to part time and low level workers to top management personnel and scientists. Recycling industry is also instigating discovery and invention of new research and development techniques to utilize greater number of materials as recyclable products, along with keeping the process of recy cling cost incentive, so that it is able to compete with the mainstream industrial production processes on the real-time scale of quality, cost and profits.Conclusion As the recycling industry is maturing and creating its own niche, it has become evident that the industry holds enormous potential in restructuring the entire economic, environmental social paradigm. On the one hand the recycling industry helps to save precious and limited natural resources, while bringing down the cost of manufacturing, and on the other it creates hundreds of thousand of jobs as a full fledged industry in itself.By reducing the pollution of land, and helping to mountain down greenhouse gases, recycling also plays a foremost part in containing the threats of global environment and securing the future of humanity on the path of consistent development and progress. Reference Pellow, D. N, Schnaiberg ,A. Weinberg , A. S 2000. Urban Recycling and the depend for Sustainable Community Development. Princeto n University Press. Princeton, NJ. Young, J. E. 1995. The Sudden New Strength of Recycling. World Watch. majority 8. Issue 4. Benefits of Recycling. 2005. Department of Environment and Conservation.Accessed online on 16. 05. 2007. http//www. environment. nsw. gov. au/resources/2005140_gov_benefitrecysum. pdf Benefits of Recycling. Hamilton County Environment Services. Accessed online on 16. 05. 2007. http//www. hcdoes. org/sw/benefits_of_recycling. htm Economic benefits of Recycling. 2006. Environmental Protection Agency. Accessed online on 16. 05. 2007 http//www. epa. gov/jtr/econ/index. htm Needleman, B. 1994. Hazardous exorbitance Recycling under the Resource Conservation and Recovery Act Problems and possible Solutions. Environmental Law. Volume 24. Issue 3. Page Number 971-1044